When you choose to invest your money with Skylands Capital, LLC (“Skylands”), you not only entrust us with your investments, but also with your personal information and financial data. Just as we are dedicated to managing your money well, we are also committed to respecting your privacy and protecting the personal information that you share with us. Federal law requires us to tell you how we collect, share and protect your personal information. Please read this Privacy Notice carefully.
In order to provide investment products and services that best suit your needs, we collect certain personal information about you from subscription agreements, account applications, investment advisory agreements and other documents. Such personal information may include your name, address, social security number or taxpayer identification number, birth date, driver’s license data, telephone number, fax number, e-mail address, business affiliations, bank information, assets, income, beneficiaries, and custodial accounts.
We do not disclose personal information to third party non-affiliates except as necessary to service your account or as permitted or required by law. In order to manage and service your account, we may provide certain personal information to various firms that provide trading and execution, settlement and custodial functions, administration, audit, tax and legal work. We may be required to disclose personal information to a government or regulatory body in connection with an examination or investigation. We may share certain account and tax information with your personal accountant, attorney and/or financial consultant per your written or verbal instructions. These non-affiliated third parties have an obligation, contractual or otherwise, to protect the confidentiality of your information and to use it strictly for the purpose for which the disclosure is needed.
We do not share your personal information with third party non-affiliates for marketing or joint marketing purposes, nor do we disclose your creditworthiness to third party non-affiliates unless specifically instructed by you. Note that Skylands does not have any affiliates (i.e., companies related by common ownership or control).
To protect your personal information, we have established security measures which include computer safeguards and secured files and buildings.
For questions about Skylands’ Privacy Notice, please contact Virginia Riesing, Chief Compliance Officer at (414) 256-3380.
This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in this Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:
Within the last twelve (12) months, we have shared each of the categories of personal information collected with non-affiliated third-party service providers as set forth above, and we collect personal information from the sources set forth above.
Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:
We do not sell any of the personal information we collect about you to third parties.
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, and disclosure of personal information specific to you over the last twelve (12) months. Such information includes:
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please e-mail us at the following e-mail address: firstname.lastname@example.org
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may use existing investor contact information that we have on file in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. For questions about this supplement, please contact Virginia Riesing, Chief Compliance Officer at (414) 256-3380.